IR 05000461/1985064

Safety Insp Rept 50-461/85-64 on 851211-13.No Violation or Deviation Noted.Major Areas Inspected:Action on 50.55 (E) Deficiency Repts & Installed HVAC Sys Related Documentation

ML20137L700
Person / Time
Site:	Clinton
Issue date:	01/21/1986
From:	Danielson D, Key W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137L692	List: IR 05000461/1985064 ML20137L688 ML20137L711
References
50-461-85-64, NUDOCS 8601280062
Download: ML20137L700 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/85064(DRS)

Docket No. 50-461 License No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, IL Inspection Conducte December 11-13, 1985 Inspector:

/W / /,20/ 8 W. Key Aate Approved By: D. H. Danielson, Chief /

/kd Materials and Processes Section Date Inspection Summary Inspection on December 11-13, 1985 (Report No. 50-461/85064(DRS))

Areas Inspected: Routine unannounced safety inspection of licensee action on 50.55(e) deficiency reports and the installed HVAC systems and related documentation. The inspection involved a-total of 22 onsite inspector-hours by one NRC inspecto Results: No violations or deviations were identifie ~

A B601200062 860122

{DR ADOCK 05000461 PDR

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DETAILS 1. Persons Contacted Illinois Power Company (IPC)

• D. P. Hall, Vice President

• J. E. Loomis, Construction Manager

• J. W. Wilson, Plant Manager

• F. A. Spangenberg, Manager, Licensing and Safety

• A. R. Shevade, HVAC Manager

• E. W. Kant, Assistant Manager, NSED

• J. G. Cook, Assistant Plant Manager

• J. S. Perry, Manager, Nuclear Program Coordinator

• J. A. Miller, Director, Startup Program

• Connel, Q.A. Manager

• R. W. Greer, Manager, Q&Ts

• K. A. Baker, Acting Supervisor, I&E Interface

• Z. Zizak, Engineer

• H.-E. Daniels, Project Manager Baldwin Associates (BA) ,,

• J. L. Thompson, Q.E. Manager The Zack Company (Zack)

• J. L. Black, Engineering Manager

• Denotes those attending the entrance and exit meeting . Licensee Actions on 50.55(e) Items (Closed) 50.55(e) (50-461/81-03): On October 2, 1981, the licensee verbally notified an NRC Region III inspector of a potential reportable deficiency per 10 CFR 50.55(e) related to HVAC materials

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installed by the Zack Compan Following six interim reports the licensee, on May 23, 1983, notified Region ~III that their investigation had identified a breakdown in the Zack Quality Assurance program and that the deficiency was reportable per 10 CFR 50.55(e). The licensee issued Stop Work Orders No. 014, No. 015, and No. 020. Region III review of the licensee's corrective actions are documented in (Section 3) this report and Inspection Reports No. 50-461/83-17, No. 50-461/83-24 and No. 50-461/84-1 .(Closed) 50.55(e) (50-461/84-20): On September 21, 1984, the licensee notified NRC Region III of a potentially reportable deficiency related to the application of an unknown coating to structural steel in the Primary Containment and that an investigation was in progres , _ _ __ _ _ _ , _

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Following two interim reports, the licensee, on April 1, 1985, reported to Region III that their investigation had determined this. deficiency was not reportable in accordance with requirements of 10 CFR 50.55(e).

During this inspection the inspector reviewed the reports documenting the results of investigations conducted by Carboline Company, KTA-Tator, Pittsburgh Testing Laboratories, and Oak Ridge Laborator Based on the investigation reports, it was determined that an inorganic zinc primer had been applied to the structural steel by Bristol Steel (the contractor) that did not meet the Carbo Zinc (CZ-ll) specification, but that the unknown primer is acceptable for use in.the containment environment and will perform as well or better than the CZ-11.- NCR's associated with this issue were reviewed by the licensee's AE and dispositioned "Use-As-Is." Following the NRC inspectors review of investigation test results, evaluations by the licensee, and assurance that where the applied coating has been damaged that these areas will be prepared and recoated with CZ-11 as required by specification, the NRC inspector has determined that the licensees actions were adequate and that the deficiencies do not create a problem for the safe operation of Clinton Power Statio (Closed) 50.55(e) Item (50-461/85-05): On May 7, 1985, the licensee notified NRC Region III of a potentially reportable deficiency per 10 CFR 50.55(e) related to inadequate design change control by Zack Company the HVAC Contractor and that an investigation was in progress. Following one interim report, the licensee on September-26, 1985, notified NRC Region III that their investigation had determined this issue to be not reportable per 10 CFR 50.55(e). During this inspection the inspector reviewed the results of the licensees investigation into this matter and has concluded that the licensee's actions and disposition are correct. See Section 3 of this report for detail . Review-of Zack HVAC Construction Activities In the period March 6 through April 25, 1980, Region III received 21 allegations from four individual The allegations concerned site construction activities at the Midland Nuclear Plant by the heating, ventilating, and air conditioning (HVAC) subcontractor, The Zack Compan Generally, the individuals' allegations dealt with material traceability, records falsification, inadequate procedures, and the qualifications of quality control personne .

The Region III investigation, conducted in response to the 21 allegations, is. documented in IE Investigation Report No. 50-329/80-10; 50-330/80-11 (March 6 through July 31,1980). The investigation disclosed quality assurance deficiencies regarding compliance with approved procedures-during fabrication and installation, and the overall traceability of materials used for fabrication.

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On May 3, 1982, an employee of Zack at the Cicero office came to Region III with concerns regarding Zack work activities. Members of the Region III staff met with him to discuss the specifics of his concern Over a period beginning on May 4, 1982, the individual provided documentation to substantiate his concerns to the Region III staf The documentation was reviewed to identify issues which warranted inspection at the Cicero Corporate Office / Fabrication Shop or at the reactor sites where Zack was contracted to perform HVAC work; LaSalle, Midland, and Clinto On August 3, 1982, the NRC Region IV, Vendor !nspection Branch began an inspection of Zack's corporate office in Cicero. The inspections identified 14 items of noncompliance with NRC requirements. Details of the inspections are documented in Vendor Inspection Reports No. 99900785/82-01 and No. 99900785/82-0 Because the Zack office in Cicero plays an integral part in the activities of the field offices, the Region III staff reviewed all docunentation regarding concerns of Zack work to identify those issues of relevance to HVAC activities at LaSalle, Midland and Clinton Nuclear Plant The issues identified which pertained to LaSalle and Midland facilities are addressed in IE Inspection Reports No. 50-373/82-51; 50-374/82-18 an'd No. 50-329/83-08; 50-330/83-08 respectivel Both Commonwealth Edison Company (LaSalle) and Illinois Power Company (Clinton) reported the Zack documentation deficiencies in accordance with 10 CFR 50.55(e). The NRC review of the Consumers Power Company efforts concluded that the identified material certification record deficiencies, at the time they were identified at the Midland facility did constitute a reportable deficiency in accordance with 10 CFR 50.55(e) and accordingly a violation was issued for failure to report this matter to the NR This and the other referenced inspection reports address the technical adequacy of the design and construction for the Clinton HVAC system and the acceptability of the QA Program which controls and assures its proper construction. The inspection methodology which was employed for this effort consisted of a five phase program. This integrated program involved a (1) followup of allegations (2) HVAC construction inspection (e.g. , systems walkdown, material traceability, etc.) (3) Zack QA Program review, (4) NRR design review, and (5) HVAC materials sampling and testing progra Followup of Allegations Region III received allegations of various HVAC deficiencies from eleven individuals. The affidavits and statements of each individual were reviewed to identify issues of technical significance. In those cases when a potential substantive technical issue was identified, the individual was contacted and a sworn statement was taken. The remaining individuals were contacted in writing and requested to inform Region III of either hardware or programmatic deficiencies which could adversely affect installed HVAC systems or components at the Midland or Clinton facilitie All technical allegations which were defined in sufficient detail

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were specifically incorporated into a special inspection (Reference NRC Inspection Reports 50-329/83-08; 50-330/83-08 conducted to review Zack HVAC activities at the Midland facility).

In a number of instances, the individuals were unable to provide sufficient details during their sworn statements to allow inspection-of their concerns by Regional personnel. These generally undefined concerns were categorized into general. subjects and were inspected as part of the five phase program documented in the Midland inspection report. With regard to the individual's general concerns, the five phase. program was structured so as to provide reasonable assurance that the concerns would be addressed. All relevant information which was gathered from the individuals was integrated into this special inspectio '

During the course of the Midland HVAC special inspection, there were several allegations received regarding potential wrongdoing and NRC impropriety. The details of each item were referred to the NRC Office of Investigations and the Office of Inspectne and Auditor for any actions which'they deemed appropriate. NRC Office of Investigation Report Nos. 3-82-025 and 3-82-057 detail the fiddings pertaining to alleged improper QA record alterations, alleged <

harassment and intimidation, alleged utility complicity relative to the Zack QA Program breakdown, and utility retaliation against Zack employees. These two reports encompass all is:ues which were referred to the Office of Investigation ,

b. HVAC Construction Inspection and Zack QA Program Review On June 23, 1982, the licensee issued Stop Work Order (SWO) No. 014 related to all safety-related HVAC work by Zack. On June 23, 1982, the licensee issued SWO No. 015 related to all attachments of non-safety hangers to seismic building structure On August 2, 1982, the licensee issued SWO No. 020 regarding all non-safety seismic, Category 1, HVAC Wor On October 25, 1982, the licensee revised SWO No. 020 to include onsite fabrication and repair of non-safety seismically designated ductwork and component '

On May 5, 1983, the licensee submitted Revision 1 to the HVAC Recovery Plan for SWO No. 014, No. 015, and No. 020, to Region III for revie ; The recovery program .is divided into 'five phases. The licensee

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requested and received Region III concurrence ~ to proceed with Phases I and II of the Recovery Pla On May 23, 1983, following completion of their investigation the licensee determined that there had been two breakdowns in the Zack (HVAC

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Contractor) QA program and submitted a reportable deficiency per 10 CFR 50.55(e). ~By letter dated July 28, 1983, the licensee j requested that the Region III staff review their actions associated with Phases I and II of the recovery plan and provide concurrence to

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proceed with Phase III. Region III reviewed the revised Zack HVAC QA program, including fabrication and installation procedures and personnel qualifications and certifications, and concurred with the licensee's request (Inspection Report No. 50-461/83-17).

On December 15, 1983, Region III received a letter from the licensee requesting the NRC staff review their corrective actions and the completed portions of the HVAC Recovery Plan for lifting Stop Work Orders No. 014, No. 015, and No. 02 Region III further reviewed-the Zack QA program and other fabrication and installation activitie (Inspection Reports No. 50-461/83-24 and No. 50-461/84-1 During this inspection the HVAC contractor's as-built drawings and associated documents relating to the installed HVAC systems were reviewed and the NRC inspector walked down selected portions of the HVAC system to compare'the installation to the as-built drawing The following as-built drawings were used during this inspection:

• No. V14-1061-1, Revision 17 Control Building HVAC Plan Elevation 800' 0" N.W. Area Control -

Roo Duct Nos. 240, 243, 245, 248, 255, 237, 220, 301, 302, 304 Hanger Nos. C6132, C6112, C6046, C6018, C6044, C6043

• No. V14-1018-4, Revision 18 HVAC Equipment Room. Control Building Elevation 825' 0".

Duct Nos. 8, 12, 21, 26, 30 Hanger Nos. C7107, C7118, C7102 Fan Nos. OVC05CB, 0VC05CA Penetration No. ICR2708

• No. V14-1018-1, Revision 21 HVAC Equipment Room Control Building Elevation 825' 0".

Plenum Nos. 6, 7 Duct Nos. 109, 110, 532, 530,.522, 519 Damper Nos. 0VA02YA, IVA004CB Fan Nos. IVR003CA, IVR003CB, OVA 004CB Hanger Nos. C7023, C7018, C7002 Silencer No. IVR006X

• No. V14-1060-1A, Revision 22 Control Building Cable' Spreading Room Elevation 781' 0".

Duct Nos.- 133, 522, 139, 546, 277, 96, 526, 228 Hanger Nos. C5033, C5123, C5128, C5131

• No. V14-1060-1, Revision 22-Control Building Cable Spreading Room Elevation 781' 0".

Hanger Nos. C511, C5117, C5025, C5034 Duct Nos. 690, 68, 24, 22, 183, 152

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• No. V14-1019-3, Revision 16 HVAC Equipment Room, Diesel Generator and HVAC Building Elevation 762' 0".

Duct Nos. 10, 541, 26, 30, 2 Hanger Nos. D4510, 04507, D4240 Penetrations Nos. IDR2360, 1DR2362 Fan No. IVD01CB

+ No. V14-1034, Revision 13 Auxiliary Building Switch Gear and Battery Room, Elevation 781' 0".

Hanger Nos. A5034, A5061, A5035, A5019, A5059 Duct Nos. 5, 47-1, 12, 23, 24, 19

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• No. V14-1061-2, Revision 16 l Control Building HVAC Plant Elevation 800' 0". N.E. Area Control Room Duct Nos. 586, 582, 511, 128-1, 539, 512 Hanger Nos. C6290, C6277, C6603, C6212, C6292 The following Field Engineering Change Notices (FECN's) and Field'

, Change Requests (FCR) were also selected and reviewed to ensure that they had been processed and incorporated into the' drawings:

• FECN No. 11071, Fire damper platform change Affected Documents Drawings N M14-1018-6, Revision N M14-1018-15

, M14C - 7236-1, Revision C I M14C - 7235-1, Revision C

• FECN No. 8444, Increase cooling in RHR heat exchanger rooms A and Affected Documents

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M14-1030-1, Revision U M14-1035-1, Revision S M14A-0029-2, Revision A M14-1034-1, Revision AB M14-1033-2, Revision M

• FECN No. 10692, Provide access panel for pressure boundary Affected Documents M14-1019-1, Revision Y M14-1019-5, Revision K

• FECN No. 1214, Expand control room pressure boundary

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Affected Documents M14-1061-8

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K-Z910 M05-1102 M14-1061-2

• FECN No. 10646, Ductwork modification Affected Documents S30-1005-05A, Revision Z

. S30-1202-058, Revision H

• FECN No. 12135, Relocate type 3 grilles Affected Documents M14-1060-1, Revision NS

• FECN No. 10947, Clearance to operate fire dampers Affected Documents Specification No. K-2910, Amendment 13 Zack Duct Standard, S-156, Revision 2

• FECN No. 11418, Installation of static pressure test ports -

Affected Document Zack Duct Standard Specification K-2910

• FCR No. 41382, Change to access panel Affected Documents M14-1061-1

• FCR No. 41179, Change to access door Affected Document M14-1018-1

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• FCR No. 33267, Incomplete design information Affected Document M14-1018, Sheet 4

' * FCR No. 35610, Incomplete design information Affected Document M14-1819-3

• FCR No. 42008, Relocate duct Affected Documents M14-1034-1, Revision A8 M14-1034-3, Revision AB

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• FCR No. 40937, Access panel change Affected Document M14-1060-1/NR

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• FCR No. 38214, Change access doors Affected Document Specification K-2910 The Nonconformance Reports (NCR) listed below were selected and reviewed for completeness and adequate corrective action:

• NCR No. 67529,. Access door damage Affected Document M14-1061-1, Revision L M05-1102-3 BQAI-190-10, Revision 2

• NCR No. 911, 888, Bolt welded to splice plate on Duct 530 F Affected Document M14-1018-/C0

• NCR No. 911208, Duct No. 220, Stiffener missing Affected Document M14-1060-1

• NCR No. 910357, Huck bolt requirement not met Affected Document M14-1061-1

• NCR No. 910389, Huck bolt loose Affected Document M14-1061-1 The Zack Company uses the Job Plan as a traveler for the installation of HVAC equipment and components. The NRC inspector selected the job plans with attached inspection reports listed below for review:

• Job Plan No. A-5061, Hanger Hanger Drawing Nc. M14-A5061-1-B Design Drawing Nos. M14-1034-1, M14-1180

• Job Plan No. 5, Duct Design Drawing No. M14-1034-1, As-built V14-1034-1 Zack Duct Standard

• Job Plan No. 50dF, Duct Design Drawing, M14-1019-3, As-built V14-1019-3

• Job Plan No. 1DR2360, Penetration Design Drawing No. M14-1019-3, As-built V14-1019-3

• Job Plan No. 541F, Duct Design Drawing No. M14-1019-3, As-built V14-1019-3

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• . Job Plan No. D-4507, Hanger l

Hanger Drawing No. M140-4507-1A ,

j Design Drawings M14-1019-3, M14-1180

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• Job Plan No. 2009/11, GRD. Type, 11 Design Drawing No. M14-1060-1, As-built V14-1060-1

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• Job Plan No. 92, Duct

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Design Drawing No. M14-1060-1, As-built V14-1060-1 a * Job Plan No. 149, Duct j Design Drawing No. M14-1060-1, As-built V14-1060-1

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• Job Plan No. 87, Duct

Design Drawing No. M14-1018-1, As-built V14-1018-1

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• Job Plan No. (A) 530F, Duct Design Drawing No. M14-1018-1, As-built V14-1018-1

• Job Plan No. OVC001YA, Damper Design Drawing No. M14-1018-4, As-built V14-1018-4

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• Job Plan No. 8, Duct Design Drawing No. M14-1018-4-P, As-built V14-1018-4-6

• Job Plan No. 220, Duct Design Drawing No. M14-1061-1, As-built V14-1061-1

• Job Plan No. 240, Duct Design Drawing No. M14-1061-2, As-built V14-1061-1

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! * Job Plan No. 586F, Duct Design Drawing No. M14-1061-2, As-built V14-1061-2 i * Job Plan No. 511F-1, Duct

. Design Drawing No. M14-1061-2, As-built V14-1061-2 i

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• Job Plan No. 2025/11, GRD l

Design Drawing No. M14-1060-1, As-built V14-1060-1 The-NRC inspector selected the following Zack. internal audit reports of their Clinton activities and Baldwin audit reports of Zack activities for review:

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• Zack Audit Report No. CB-ZC-INT-85-11

, Date - April 1-5, 1985 t

Scope - Welder Qualification and Verification, FQCP-9.2 and FCP-4

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• Zack Audit Report No. CB-ZC-INT-85-27 Date July 15-19, 1985 Scrpe - Maintenance of Q.A. Records '

and Records Turnover (QAI-28 and FQCP-17.2)

• Zack Audit Report No. CB-ZC-INT-85-40 Date - October 27-28, 1985 Scope - Implementation of Procedures

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FQCP-8, FQCP-1C.0 and FQCP-22

• Baldwin Audit Report No. E-643 Organization - Zack Date - May 21-24, 1984 Scope - Verify implementation of the Zack quality program and review procurement activities involving Baldwi i

• Baldwin Audit Report No. E-583-A

, Organization - Zack Corporate, Date - July 9-10, 1984 Scope - reaudit to verify completion of Corrective Actions taken,r= lated findings and concerns of Baldwin

! Audit E-583, conducted on November 21-23, 1983.

l The NRC inspectors reviews and as-built walkdown of the installed

' HVAC systems has determined that the HVAC systems installed in the Clinton Nuclear Power Station meet the. design specifications.

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c. NRR Design Review This effort involved a review of the Clinton HVAC structural design adequacy. The review and ~ evaluation was performed by the Office of

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Nuclear Reactor Regulation who has primary responsibility for design adequacy. The results of their review are included in Attachment i d. HVAC Materials Sampling and Testing Program One facet of the Region III inspection of the Midland HVAC system (Reference Inspection Report No. 50-329/83-08; 50-330/83-08)

involved the implementation of a materials sampling and testing

program. The purpose of the program was to provide additional confidence that the installed materials were in accordance with applicable ASTM standards. Representatives from Region III selected samples of HVAC structural material for removal and subsequent testing. The samples were selected from five safety-related systems and stock material Because the Zack office in Cicero plays an integral part in the activities of the field offices, because of the extensive materials sampling and testing program that was conducted at the Midland facility as well as at the LaSalle facility-(Reference Inspection Report No. 50-373/82-51; 50-374/82-18) and because fabrication materials were procured by the Zack Cicero office for the LaSalle, Midland and Clinton facilities with no designation as to which

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facility they would go to, Region III concluded that the Midland and LaSalle materials testing programs provided reasonable assurance that the materials used at Clinton met applicable ASTM Specifications and would provide sufficient margins of safety to failure under normal and design basis accident condition . Exit Meeting The inspector met with licensee representatives (denoted in Persons Contacted Paragraph) at the conclusion of the inspection on December 13, 1985. The inspector. summarized the scope and findings of the inspection noted in the repor The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietar